BREYER, Circuit Judge.
A partnership called the Sunset Construction Co. ("Sunset") bought heavy construction equipment in 1979 and 1980 and leased it to two related companies, Connor Construction Corp. ("Connor Construction") and Catamount Construction Co. ("Catamount"). One of Sunset's partners, Eugene Connor, and his wife claimed that Sunset's purchases entitled it to an "investment tax credit," ("ITC"), 26 U.S.C. § 38 (1982) (amended 1986), which they, in...
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